VELASCO, JOSE LEOZAR L.

Republic of the Philippines

REGIONAL TRIAL COURT
Branch 1
Malolos, Bulacan

Frodo “nine fingers” Baggins, Plaintiff, CIVIL CASE No. 1

- versus – FOR: Damages for Loss of earning capacity, Moral

damages and Attorney’s Fees.

Witch-king of Angmar, Defendant.

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COMPLAINT

COMES NOW, plaintiff, Frodo Baggins, by counsel, and unto this Honorable Court, most
respectfully avers THAT:

1. Plaintiff is a Filipino, of legal age, married, and residing at Bag end, Barangay Shire, Malolos,
Bulacan, where he may be served with summons, papers and other process of this Honorable Court to
Mithrandir Law Firm, Suite 704, Green Dragon Inn, Malolos, Bulacan.

2. Defendant Witch-king is a Filipino, of legal age, single, and residing at Minas Morgul, Malolos,
Bulacan where he may be served with summons, papers and other process of this Honorable Court.

3. On October 18 2018 at around 9pm, Plaintiff Frodo Baggins along with four Companions,
Samwise Gamgee, Peregrin Took, Meriadoc Brandybuck and Aragorn “Elessar” chieftain of the Dunedain
and heir to Isildur, last king of Gondor, were camping at Amon-Sul, Malolos Bulacan. The five were on a
a perilous journey to destroy the one ring by casting it into the fires of Mount doom, Malolos, Bulacan.
As the group were having their supper, they were ambushed by nine Ring wraiths, former kings of men
and who above all else, desired power.

4. One of such ring wraiths was the defendant, Witch-king of Angmar. The nine ring wraiths
demanded the one ring from plaintiff who refused to give it away willingly even at sword point.

5. Upon plaintiff’s refusal, the defendant, Witch-king of Angmar stabbed said plaintiff in his left
shoulder, who fell down and blacked out. The four remaining companions defended their friend and
vanquished the nine ring wraiths.
 VELASCO, JOSE LEOZAR L.

6. Plaintiff was hospitalized for more than 30 days and the wound never fully healed even with the
assistance given by the best elven doctors in Rivendell, Malolos, Bulcan

7. Defendant Bonifacio Cruz promptly denied liability for reason that his vehicle was used and
driven without his knowledge and consent by Aurelio Tuadles at the time of the accident.

8. As a result of the injury, plaintiff was declared to have suffered permanent total disability and
must be confined to the undying lands for the rest of his natural life. Hence, defendant must be made to
pay for damages for plaintiff’s, in the amount equivalent to ONE MILLION PESOS PESOS (P
1,000,000.00).

9. Due to the mortal sword wound of plaintiff, he suffered mental anguish and serious anxiety.

10. Consequently, Plaintiff was constrained to engage the services of counsel to whom it obligated
itself to pay as Attorney's Fees the amount equivalent to TWENTY FIVE PERCENT (25%) of the total
amount to be adjudged in favor of plaintiffs, and the costs of this suit.

PRAYER

WHEREFORE, the above premises considered, it is respectfully prayed of this Honorable Court
after hearing on the merits, that:

a. Defendants be ordered to pay for damages for death in the amount of ONE MILLION
PESOS.

b. Defendant be ordered to pay moral damages in the amount of FIVE HUNDRED

THOUSAND PESOS (Php 500,000.00);

c. Defendants be ordered to pay attorney’s fees in an amount equivalent to TWENTY FIVE

PERCENT (25%) of the total amount to be adjudged in favor of plaintiffs;

d. Defendant be ordered to pay the costs of this suit.

Other reliefs just and equitable under the premises are likewise prayed for.
 VELASCO, JOSE LEOZAR L.

For the Plaintiff

By

ATTY. Gandalf Istari

Mithrandir Law Firm, Suite 704, Green Dragon Inn.,
Malolos, Bulacan
PTR No. 1247838 1-20-2018 Malolos City
IBP No. 911117 1-21-2018 Malolos City
Roll No. 89994
MCLE Ex. No. 111-000748 1-13-2018
For 3rd compliance

Republic of the Philippines )

Malolos, Bulacan )s.s

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VERIFICATION AND CERTIFICATION AGAINST FORUM-SHOPPING

I Frodo Baggins, Filipino, of legal age, married and a resident of residing at Bag end,the shire,
Malolos, Bulacan after having been duly sworn to in accordance with law depose and say, THAT:

That I am the Plaintiff in the above-entitled case; That I have caused the preparation of the
above Complaint and I have read the same and knows the contents thereof; That the allegations
contained therein are true and correct of my own personal knowledge.

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of October, 2018 at Malolos
City, Bulacan, Philippines.

SUBSCRIBED AND SWORN to before me this 30th day of October, 2018, by Frodo Baggins, who
exhibited to me her Voter’s ID No. 12345 issued at Malolos City, Philippines on May 12, 2015.

WITNESS MY HAND AND SEAL.

Doc. No. 0012;

Page No. 003;
Book No. 001;
Series of 2012.
VELASCO, JOSE LEOZAR L.